Rostami

I. BACKGROUND

1 At the pleading stage, the Court accepts as true all well-pleaded factual allegations and 2 construes them in the light most favorable to the plaintiff. Carijano v. Occidental Petrol. Corp., 3 643 F.3d 1216, 1222 (9th Cir. 2011) (accepting facts alleged in complaint as true in evaluating 4 motion to dismiss for forum non conveniens); Reese v. BP Exploration (Alaska) Inc., 643 F.3d 5 681, 690 (9th Cir. 2011) (accepting facts as true in determining motion to dismiss under for failure 6 to state a claim). The following facts derive from the allegations in the Complaint.1 7 Defendant Hypernet is a start-up technology company that described its business plan as 8 the creation of a computing network—the “Hypernet Protocol” or “Hypernet Platform”—capable 9 of providing “true parallel computing” as a public resource via a decentralized platform that would 10 connect buyers and sellers of computing power. Compl. ¶¶ 2–3, 35. Hypernet was incorporated 11 in the Cook Islands, with its headquarters and principal place of business in Palo Alto, California. 12 Id. ¶¶ 7(i), 11; Ex. A at 2. The Cook Islands Ministry of Justice does not have a record of the 13 formation or…